In general
If—
(i)#
without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States,
(ii)#
under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and
(iii)#
the taxpayer chooses the benefits of such treaty obligation,
subsections (a), (b), and (c) of this section and sections 907 and 960 shall be applied separately with respect to each such item.